AUDITROL Institute
Deep analysis on the forces reshaping financial services governance, from regulatory policy to artificial intelligence.
Below the Line Is Not the Same as Finished: SR 26-2 for Banks Under $30 Billion
SR 26-2 says it is most relevant to banks above $30 billion. Many institutions below that line have read that as permission to wait. Examiners have not. They are already using the new guidance as their picture of sound practice, at banks of every size. Here is how to tell whether it reaches you, and four moves that cost less now than they will later.
You Are in Scope. Now Close the Distance: SR 26-2 for Banks Above $30 Billion
If your bank holds more than $30 billion in assets, the scope question around SR 26-2 is closed. The open question is how far your program sits from the new standard. Most large institutions have at least three of five high-visibility gaps still open, and the examination teams coming to test them know exactly where SR 11-7 programs fall short. Here is where to look first.
SR 26-2 Moves the Pen to the Bank: What the New Model Risk Guidance Asks of You
For fifteen years, SR 11-7 told banks what a sound model risk program looked like. SR 26-2 asks a harder question: can you defend the program you built? The new guidance is shorter, less prescriptive, and not enforceable on its own, yet it hands every institution a set of decisions examiners will test. Here is what changed, what most people are misreading, and where to start.
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